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Use of the Canada Organic Logo on imported organic products

Although the Safe Food for Canadians Regulations (SFCR) came into force on January 15, 2019, certain requirements may apply in 2020 and 2021 based on food commodity, type of activity and business size. For more information, refer to the SFCR timelines.

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To: Certification bodies accredited by the Canadian Food Inspection Agency (CFIA) and conformity verification bodies designated by the CFIA.

The purpose of this memo is to clarify when an organic product is considered an imported organic product in accordance with section 357(1) of the Safe Foods for Canadians Regulations (SFCR).

Section 354(d) of the SFCR requires any imported product certified under the Canada Organic Regime and bearing the Canada Organic Logo on the label to have the statement "Product of "immediately preceding the name of the country of origin, or the statement "Imported" in close proximity to the legend. The intent of section 354(d) of the SFCR is to prevent consumer confusion regarding the country of origin of the product, as the logo contains a maple leaf and the words "Canada Organic".

Imported products under the section 357(1) of the SFCR

Under the SFCR, imported organic products are those wholly produced and processed outside of Canada. No processing steps that modify the nature of the product, can be performed in Canada, such as:

addition, removal or combination of one or more ingredients

physical or chemical processing, including grinding and blending

Packaging and labelling activities performed in Canada, including certification of those activities, are not considered to modify the nature of the product.

Examples of imported products under the SFCR:

taco seasoning packaged in the same container that will be sold to the consumer

nuts imported in bulk (already roasted and salted) that are only canned in Canada

Examples of products not considered imported under the SFCR:

macadamia nuts imported in bulk that are then roasted, salted and canned in Canada

chocolate imported in bulk that is then blended with other products, packaged and labelled in Canada

Please note that the requirements concerning the identification of the country of origin when using the Canada Organic Logo on a label are different than the requirements found in the Guidelines for "Product of Canada" and "Made in Canada" Claims. Requirements for these latter requirements are not verified by the CFIA-accredited Certification Bodies under the Canada Organic Regime.

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